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4. Any and all assets of the Defendant about which the Plaintiff may
personal property, including,
5. Any assets andior real, personal, tangible and/or intangible
to answer to Plaintiff,
of the Court, on or before the second day following the return date, then and there
and says:
M&O CORPORATION, in a civil action in which the Plaintiff complains
26,2010'
January 19, 1988 and worked for Plaintiff until his resignation on February
10
His
4. During the course of his employment, Defendant was a sales person/project manager.
he sold which
duties involved sales of commercial HVAC equipment and managing the projects
workers and subcorttractors, job billing and approval of supplies and vendor invoices'
5. During the course of his employment, Lazowski devised and engaged in a scheme
("Reinhart").
whereby he submitted fake M&O purchase orders to an existing supplier, Ronald Reinhart
M&O projects, but Lazowski instructed Reinhart not to supply the equipment listed on the purchase
order but, rather, to simply submit to M&O an invoice corresponding to the purchase order'
for equipment that Lazowski, in fact, did not order and that M&O did not receive. Because the invoices
referenced projects for which Lazowski had responsibility, the invoices were forwarded to Lazowski
for
approval.
7. Upon receipt of these invoices, Lazowski approved payment for the amount stated and
g. Upon Reinhart's receipt of these payments, Reinhart deposited the funds received from
M&O and split the amount received with Lazowski in the amounts that Lazowski directed, with the
11
lion's share going to Lazowski.
g.Reinhart'spaymentstoLazowskiweremadebycheck.
payments of at least
10. As a result of Lazowski's above-described scheme, M&O made
scheme.
12. The benefit to Lazowski's unjust because M&O received no value for the payments it
1.-13 paragraphs l-13 of the First Count are hereby incorporated and made paragraphs 1
14. Lazowski's receipt and retention of money paid by M&O as a result of his scheme
as
benefit.
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16. As a result of Lazowski's conversion, M&o has suffered damages'
Third Count.
knowing that
17. Lazowski received and accepted the funds tendered to him by Reinhart,
those funds were paid by M&o as a result of Lazowski's scheme to wrongfully obtain payment for
or deceptive acts or
17. Lazowski,s acts, as alleged, constitute unfair competition and unfair
r3